April 2004
The Big Conversation

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EHJ April 2004, pages 101-105

Four years after its launch, what you really think of the Food Standards Agency

The Food Standards Agency is four-years-old this month and is currently putting together its strategy for the next five years. So this month EHJ has handed over these five pages to the profession to see how you think the agency has performed and what changes you would like to see take place. All 33 of the CIEH food groups were asked for their opinion while EHPs were invited to put forward their views via EHCnet.

In general, the profession believes that the FSA is doing a good job and has been successful in raising the profile of food safety over the last few years by providing a focus for food issues. The imported food division comes in for particular praise at a time when port health is facing increasing pressure, following the foot and mouth outbreak.

However, there are recurring criticisms of the FSA. The most common is its failure to recognise the work being done through local enforcement, particularly in its dealings with the press. EHPs feel there is a tendency for the FSA to claim credit, rather than see local authorities as a partner, also deserving of recognition. Some believe that this is creating unnecessary barriers with local government.

Food hazard warnings are seen as too frequent and taking up precious resources. There are calls for the FSA to distinguish between recurring threats, such as Sudan red, and new hazards. EHPs also feel that the FSA should respond more quickly to requests for information and guidance, which FSA staff often fail to recognise are time-sensitive.

FSA training on subjects like food imports and cheese making are seen as being of a high standard, creating a demand for more training of a similar quality in other areas of enforcement. As for the future, the plea from EHPs is for the FSA to be less paternalistic and to acknowledge its own mistakes. The current debate about the accuracy of returns was cited as an example of the FSA failing to accept the part it played in the system breaking down.

Below are a sample of responses representative of those received, along with a comment from the CIEH. The responses have been edited, only to avoid repetition.

YOUR VIEWS:

"The FSA's remit to tackle food safety from farm to fork is certainly the best approach. The public also sees this as the correct agenda. Where the FSA might fall down is in trying to map this agenda onto existing, mainly local government networks. You must have sympathy with any agency seeking consistency of resource allocation and quality of enforcement across at least four tiers of local government and two professions. Also, who is able to act on the nutrition and obesity debate? There is no real coordinated infrastructure in the UK to match the voice of commerce. That being said the FSA has scored a couple of own goals. Their software programmes covering local authority monitoring data and their obsession with Sudan red food hazard warnings are seen by some as weaknesses."
- Stephen Young, food and trading standards manager, Bath and North East Somerset Council

"The FSA should be congratulated for raising the profile of food safety over recent years, particularly with the release of the television advertisements aimed at the catering sector last year. It also offers more support to environmental heath departments than its predecessor. But its response to technical questions could be more prompt and decisive. There is, for example, a need for greater clarification over authorisation under the European Communities Act. This is one area where communication between the FSA and Lacors needs to be improved. The FSA could also provide more help with resourcing problems faced by local authorities. The large number of food hazard warnings issued is a strain due to the time taken to draft press releases and contact businesses. Would it be possible for the FSA to put pressure on companies to issue press releases? We feel the FSA reporting and monitoring regime limits the resources local authorities can direct to premises that they feel are most in need. This also reduces local authorities' flexibility and prevents the best use of resources. On the positive side, the standard of publications aimed at food businesses is high and easy to understand. The distribution of information directly to food businesses is welcomed. The FSA website is continually improving, but there is still work to be done to make the website more user friendly to enforcement officers."
- West Midlands Food Group

"There is a question as to whether the inspection regime is sustainable. Apart from the obvious veiled threat of an FSA audit, the whole thing is a source of considerable stress for all involved. It is true that we get fewer bad premises because we inspect more regularly. But the main problem is people with no food safety skills wanting to operate food businesses - something we have little control over. On the good side, the web information is very useful, with procedures and policy clearer than they used to be. It is, however, frustrating and difficult having to interpret obscure EU legislation for small-time operators. This is one area where things could improve. We are happier with some of the guidance documents the FSA produces although they have a long way to go to catch up with the presentation of the HSE guidance. The framework agreement was a monster but there was nothing in there that we shouldn't already have been doing. The FSA should be more sympathetic to smaller authorities where EHPs are generalists. In some authorities there are just two EHPs providing the workforce of less than one full-time equivalent on food."
- Northumberland food liaison group

"Here at the Hull and Goole Port Health Authority we have a very good working relationship with the relatively new imported food division of the FSA. Many of the staff in the division are ex-port health officers and so are very knowledgeable and give valuable assistance and advice. The profile of imported food control has never been higher following the foot and mouth epidemic in 2001. The FSA is leading in the government's demands for a 'step change' in import controls. We have also been subject to a rigorous imported food audit last December, based on the framework agreement. I found the process to be challenging but fair, with a great deal of support from the agency. The FSA has been instrumental in securing valuable extra government funding for imported food sampling. They have also given commitment to providing low-cost or no-cost officer training. Together with the Association of Port Health Authorities, the FSA has proved to be an effective and welcome organisation. I hope that they will maintain the momentum."
- Laurence Dettman, chief port health inspector, Hull and Goole PHA

"Clearly both the public and EHPs have benefited from the existence of the FSA. The framework agreement alone has really improved the lot of the lead food control officer. The FSA has, controversially, spent a lot of money to promote itself as well as food issues. In my view, however, it should have listened to EHP liaison groups about how to use some of the money more wisely. For instance, the FSA has never really coordinated its main hygiene campaign with the work of all local authorities. Targeted back-up activity would have given considerably more emphasis to the food safety messages. In fact, the FSA hardly ever mentions, let alone promotes, the work of EHPs despite surveys that confirm that most businesses gain all of their food safety knowledge from EHPs. For all its talk about the importance of partnerships, the FSA has failed to be a coordinated partner of local authority officers. At the enforcement stakeholder forum last December, FSA chief executive Dr Jon Bell said he recognised this to be a problem and confirmed that the FSA would rectify the problem. I wait with interest to see whether there are reports of success at future meetings."
- Steve Ramm, chartered environmental health practitioner

"The creation of the FSA has been a good thing. However, the agency's role is too skewed toward exposing the perceived weaknesses of local food authorities, rather than being a support. While poor practice should be exposed, it is also necessary to provide appropriate praise and support. The FSA is guilty of having become an ivory tower. It has lost a great deal of face with those who enforce food safety law as a result. We would like to see a genuine shift in attitude from auditor, namer and shamer to valued partner. There should be more consultation with EHPs. Possibly representatives from the FSA could attend regional food study group meetings. There should be more cross secondment between environmental health and the FSA to see how the other half works. The CIEH should also play a stronger role in defending local authorities who are constantly under political and financial pressure, rather than seemingly chastising them in chorus with the FSA."
- East and West Sussex group


"The FSA is doing well and is more accessible than a number of other government departments. The website is very informative and becoming more user friendly. It also provides a focus for raising public awareness on food issues with knock-on effects for enforcement services. This is supported by the TV and press campaigns. More people are coming to food enforcement services with queries or complaints prompted by reading the website or seeing items in the press or on TV. We would like to be given more time to apply for available FSA funds. Examples are funds being made available for imported food sampling work and grants for supporting the food hygiene campaign. More time would allow authorities to better plan, implement and evaluate these initiatives. The audit programme is producing constructive information and identifying where additional resources need to be focused, although in the current financial climate this means resources are pulled from other areas. However, audits seem to be failing to identify good practice. There has been an undue delay in issuing the revised code of practice, which does not appear to have been given the priority it deserves. There has also been little guidance forthcoming on the new consolidated regulations. There is likely to be a very short lead-in period and the brunt of the problems will fall on local authorities that currently have little information."
- The CIEH Yorkshire and Humberside food technical committee and member authorities

"The FSA has responded swiftly and constructively to the government's 'step change' initiative on imported food controls. But it needs to ensure resources are available to implement all EU legislation, which needs to be interpreted pragmatically, focusing on risk. The order that enables enforcement of food hygiene legislation aboard ships and aircraft is to be welcomed, and with proper guidance this will offer greater protection to travellers and crews. On the negative side, the dilatory way that atypical DSP in shellfish has been handled has caused major problems for food authorities. We can but hope that the FSA will learn from this debacle. The agency has also failed to respond to growing evidence that salmonella in Spanish eggs is a significant public health issue. There is still a need for the agency to coordinate efforts between its divisions more effectively and also for the ongoing turf war with Defra to be resolved once and for all."
- Jon Averns, port health services director, London Port Health Authority

"The FSA should be congratulated on raising the profile of food safety issues, imported foods, initiating national food safety campaigns and providing funds for low cost training for enforcers. However, enforcers do find advice given by the FSA on enforcement issues often nebulous and impractical. Enforcement advice should be clearer, with the FSA providing models and examples of best practice."
- Leicestershire food liaison group

"Publicly, the FSA appears to give little credit to local authorities for their efforts in food law enforcement while being only too quick to sing its own praises. Clearly some enforcement authorities are better managed than others. Those that underperform need to be brought up to speed. But if the FSA was prepared to more openly acknowledge the positive contributions made by local authorities, I, and many of my colleagues might see it in a better light. On the plus side, the FSA's strategy for reducing reported incidences of food poisonings and foodborne disease appears to be working, or at least that's what the figures are indicating."
- John Dunne, team leader - food safety, Harrow LBC

"The FSA needs to take a lead role in tackling the causes of obesity and long-term ill health from poor diet, working more closely with industry and improving labelling. It also needs to address the reported rise in allergies and food intolerance, with consumers being better able to identify foods that may cause a reaction. The agency should also do more research into detecting GM in foods. The need for traditional meat inspections should be looked at without handing control to the industry."
- Sheffield MDC

"Members of the east of England small ports network have benefited from the expertise and positive 'can do' approach of the FSA's imported food division. Unfortunately, when contacting the FSA with urgent requests for information, sometimes responses are not within the tight deadlines that ports have to operate to. The FSA also moves staff about, which is frustrating for authorities who, having obtained the name of a knowledgeable contact, find the person has moved on. We hope that these issues may be resolved by the FSA establishing a single enquiry point on imported food issues with a faster response time. Overall, the imported food division is helping to improve recognition of small ports and continues to help us improve service delivery."
- The Association of Port Health Authorities' east of England small ports network

"The FSA is more open and provides a focus for food-related issues. But staff produce guidance that makes unrealistic demands on small- to medium-sized enterprises. An example is documented Haccp for a local sweet shop. Information seems to be sent out from an 'ivory tower' and is divorced from reality. The FSA is also too focused on larger business, resulting in a 'big business bias' on the development of food safety guidance. Councils work on added value issues such as advice and training, which does not appear to be adequately recognised. Recommendations for the future are:

  • regionalise the FSA to reflect the newly established government regions, like the Health and Safety Executive
  • greater joint working to produce guidance. Working groups should have representatives from the FSA, local authorities, and small and large businesses
  • more flexibility will be required in the requirements to inspect all premises, especially if we are required to promote Haccp. Current research shows contact time with trial businesses is eight to 10 hours each
  • reviews of the statistical returns and risk rating system returns are needed in partnership with stakeholders."

- Dorset food group


VIEW FROM THE CIEH

Since its inception, the FSA has made great strides in addressing food safety issues. It is still, however, a relatively young organisation and so developing. Comments, while generally positive, identify perceived areas of improvement. One emerging theme is partnership. There are plenty of partnerships in the public sector and experience shows that some work better than others. Recognising and valuing the contributions of partners, trust, patience and good communication are all key to success.

The positive criticism that has come out of this exercise should allow enforcement partnerships to improve. On the key issues of consultation and communication, the CIEH currently discusses emerging issues with members through mechanisms like the expert advisory panel network and through EHN and EHJ. New contributors to the virtual consultation panel are always welcome, with views fed back to the FSA.
- Jenny Morris, policy officer

To feed back views, contact Jenny Morris on 020 7827 5835 or e-mail j.morris@cieh.org